Introduction
Healthcare organizations are required to determine how their wastes are regulated prior to disposing of them. Unfortunately, this is a complex process as there are many applicable regulations at both the Federal and State level, including but definitely not limited to:
- Controlled substance requirements in accordance with the Drug Enforcement Agency (DEA)
- Hazardous waste regulations in accordance with the Environmental Protection Agency (EPA) and individual state requirements
- Infectious waste requirements in accordance with state-specific requirements (requirements greatly vary between states)
It is also imperative to keep in mind other requirements that are typically associated with healthcare waste management:
- The Occupational Safety and Health Administration (OSHA) for safely working with chemicals and bloodborne pathogens
- The Department of Transportation (DOT) for shipping of hazardous materials
- Local Publicly Owned Treatment Works (POTW) who regulate what can be placed down the drain
Healthcare Waste Types
Controlled Substances
What Are They
Common examples of controlled substances include morphine and hydrocodone. Take a look at the DEA's Controlled Substance Schedules for a comprehensive list.
What Requirements Apply
When disposing of controlled substances, you must meet the DEA's non-retrievable and destruction standards (see the entire DEA disposal regulation). Put simply, this requires that you follow a two-step process:
- Placement into a suitable neutralizing media or use of a solidifier for liquid controlled substances.
- Placing the neutralized container into a non-hazardous pharmaceutical waste container that will be sent out for incineration.
Hazardous Waste
What Are They
Some medications meet the definition of hazardous waste under the Resource Conservation and Recovery Act (RCRA). Below is an outline of the different categories of hazardous waste that can apply to healthcare waste as well as a few examples for each category.
| Hazardous Waste Type | Definition | Examples |
|---|---|---|
| Listed on RCRA P-List | These chemicals are specifically listed as hazardous wastes. However, in most States, to be managed as a hazardous waste they must be: (1) the sole active ingredient and (2) not have been used for their intended purpose. |
**This includes empty containers unless they have been triple rinsed. |
| Listed on RCRA U-List | These chemicals are specifically listed as hazardous wastes. However, in most States, to be managed as a hazardous waste they must be the sole active ingredient and not have been used for their intended purpose. |
|
| Characteristic for Ignitability | Has a flashpoint less than 140F, is a DOT oxidizer, or is a flammable aerosol. |
|
| Characteristic for Corrosivity | Has a pH less than 2 or greater than 12.5. |
|
| Characteristic for Reactivity | Can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water. |
|
| Characteristic for Toxicity | Contains regulated levels of one of 40 chemicals. |
|
(1) Epinephrine has been excluded from the definition of hazardous waste at the Federal level, but some states have not adopted that exclusion.
What Requirements Apply
If you generate hazardous waste, specific requirements will depend on the quantity generated each month. These requirements will generally include:
- Registration with EPA to obtain an EPA ID Number
- Managing waste materials in appropriate and labeled containers while on-site
- Routinely inspecting waste containers
- Training employees
- Having emergency plans in place
- Documenting waste shipments
Infectious Waste
What Are They
Infectious waste, also known as regulated medical waste, is generally considered to be any waste with the potential to spread disease through blood or other types of contamination if not handled properly. Common examples include:
- Pathological waste such as:
- Liquid blood or other potentially infectious body fluids from humans or research animals
- Wastes that release blood or other potentially infectious body fluids when compressed
- Sharps from either human or animal use
- Human and animal vaccines
- Human or animal body parts such as organs, tissue, and surgical specimens
- Infectious cultures and laboratory equipment contaminated with such cultures
What Requirements Apply
Most states have strict regulations on how to manage infectious wastes. Common requirements include:
- Preparation of an Infectious Waste Management Plan
- On-site storage requirements (including packaging and labeling requirements)
- Employee training (may include both waste management and DOT shipper training)
- Proper disposal using a registered shipping company
It is also important to note that OSHA has a comprehensive set of regulations that includes similar requirements (and many more). You can find OSHA's Bloodborne Pathogens regulations at 29 CFR 1910.1030.
Non-Hazardous and Non-Infectious Waste
What Are They
If a waste material does not fall into any of the above categories, it likely falls into this category. However, this is by no means an exhaustive study so please carefully review your state's regulations when characterizing healthcare industry wastes.
What Requirements Apply
These waste items may be wrapped securely in trash bags for disposal in the normal trash.
Other Frequently Asked Questions
What About Wastes That Are Both Hazardous and Infectious?
You will need to manage these wastes in accordance with both sets of regulations.
What About Sharps?
OSHA defines a "sharp" in workplace safety as a medical instrument or object capable of penetrating the skin, causing potential exposure to bloodborne pathogens. Sharps include:
- Needles
- Syringes
- Scalpels
- Broken glass
- Razor blades
- Dental anesthetic carpules containing residual blood
- Wires, sutures, and dental files
- Any items that can cause injury through cuts or punctures
Sharps are of particular concern in healthcare settings, laboratories, and other environments where employees handle medical equipment, conduct procedures, or deal with potentially contaminated materials. OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030) outlines guidelines and requirements for the safe handling, disposal, and prevention of sharps-related injuries to protect employees from exposure to bloodborne pathogens like HIV, hepatitis B, and hepatitis C.
Employers must implement practices and provide training to minimize the risks associated with sharps and to ensure appropriate engineering controls (such as sharps containers) and personal protective equipment (PPE) to prevent injuries and the potential transmission of bloodborne diseases.
How Can EHS Software Help?
EHS Software, such as Ecesis, can help healthcare organizations centralize and automate waste management compliance. Centralizing these processes makes sense of complex regulations and saves you time so you can focus on the care of your patients.
Waste Tracking
Characterize and track waste streams, containers, and shipments.
Employee Training
Track and deliver waste handling and safety training requirements.
Inspections
Complete recurring waste area inspections with the mobile app.
Task Management
Track recurring compliance tasks and deadlines automatically.
Document Management
Centralize policies, procedures, and compliance documentation.
Compliance Obligations
Track complex regulatory requirements and deadlines.
